Follow-up on Health Impact Assessment Comments

Documentation provided by this webpage consists of an excerpt of written comments provided to the City of Naperville, Illinois, as part of a public proceeding conducted by the City of Naperville, Illinois (the City) in March 2013 held pursuant to Public Utility Regulatory Policies Act of 1978. This type of public proceeding is commonly referred to as a “PURPA hearing.” Comments pertain to the Naperville Smart Grid Initiative (NSGI).

In prior comments, it was asserted that: “Deployment of an Advanced Metering Infrastructure (AMI) may negatively affect the overall health of the residents of the City, especially the vulnerable populations, such as the elderly and lower-income or disabled persons.” Furthermore, it was stated that deployment of an AMI could result in an increased exposure of its residents to heat or cold. “Residents and consumers living on fixed incomes and constrained budgets, including vulnerable populations, would feel pressured (through marketing and incentives) to participate in energy control and pricing programs offered by the City that charge different rates at certain times of the day or require the consumer to reduce energy consumption in order to receive a discounted rate. This behavior will result in an under-usage of electricity resulting in extremes for the indoor temperatures of affected consumers.” Finally, it was claimed that:

“It has been shown that exposure to temperatures outside of a ‘moderate range’ increases the likelihood of hospital emergency department visits, hospitalizations, and premature death.”

The above statement was based upon direct testimony presented before the Illinois Commerce Commission in 2012. Although “moderate range” is not explicitly defined, it may be logical to ask for further clarification on the usage of this term.

From a document entitled, “Affordable Home Energy and Health: Making the Connections,” published by the AARP Public Policy Institute, in June 2010, I put forward supplementary quotations and comments as given in the paragraphs that follow to provide further insight on the use of the term “moderate range,” as it applies to indoor residential temperatures and temperature changes.

“Evidence connects temperature, health, and safety. Heat and cold challenge the body’s ability to maintain a steady core temperature. Anything that impairs the body’s ability to regulate its own temperature heightens vulnerability. Significant risk factors include the following:

Dependency and frailty signaled by cognitive impairment or limited mobility

While exposure to heat and cold kills thousands of people prematurely in the United States each year, the death toll underestimates the true impact of temperature on health. For example, mortality statistics do not distinguish between outdoor and indoor exposure to unsafe temperatures as the cause of death and do not account for a range of adverse health consequences that fall short of premature death. For many older adults, it is the aggravation of existing health conditions from exposure to even moderate temperature changes [emphasis added], rather than extreme exposure, that is both of concern and difficult to measure.

Adverse health outcomes, including death, become more likely as temperatures deviate from a moderate range [emphasis added].Temperature thresholds beyond which adverse health outcomes occur reflect local climate, access to resources (such as prevalence of central air-conditioning), and acclimatization (how adapted the population is to local conditions). Greater numbers of temperature-related deaths occur in warmer regions exposed to unseasonable cold and colder regions experiencing atypical warming. Lack of acclimatization also explains why heat waves early in the summer are more deadly than those later in the season.”

“Health is at risk directly through exposure when heat is turned down in winter or air-conditioning is turned off in summer… Substandard dwellings may be hard or impossible to keep within a moderate temperature range, and excessive humidity may lead to mold growth that increases the likelihood of respiratory disease.”

“The ultimate goal of home heating and cooling is to maintain moderate [emphasis added] indoor temperatures. Meeting energy needs affordably has been a consistent challenge for too many households and could become even more problematic as energy prices increase in response to efforts to reduce greenhouse gas emissions.”

“Some recent policy initiatives pose threats to the health of older people. At the local, state, regional, and national levels, policymakers and industry groups have initiated efforts to shift and dampen consumer demand for electricity. These efforts have focused on the deployment of advanced metering technology and a variety of new pricing programs that vary the price of electricity based on the time of day.”

These demand response policies create financial incentives and indirect pressure to reduce consumption. These policies also pose a potential threat to health and safety for consumers who must pay more for electricity because they cannot shift their usage from higher cost peak times to lower cost off-peak times or because they feel pressured to participate in voluntary energy programs in attempt to lower monthly utility bills.

“Financial stress poses indirect threats when households must make difficult decisions in the face of competing demands for limited dollars. This scenario is commonly described as ‘heat or eat,’ making vivid the trade-offs between paying a utility bill and purchasing groceries or medications.”

I have discovered that another Naperville resident has facilitated making my point about the negative health impact of an AMI deployment in a somewhat indirect way.

In commenting on the City’s possible adoption of Federal Energy Standards, one resident has commented as follows: “I am concerned about the time based rate schedule because I am retired, 84 years old and have some heart and respiratory issues, otherwise in reasonable health, all things considered. … Time based rates mean that we would have to pay more because we stay at home. The result is, most likely, that our bills would exceed our budget. I suppose that I could go camp out in the library every afternoon in order to keep from freezing in winter or suffering heat stroke in the summer. I do think however that this [is] an unrealistic solution.”

In the instance above, it appears that a City resident is genuinely under the impression that the Time-of-Use rates will be mandatory and that such rates would negatively affect his health as well as his budget. This by itself represents a serious problem for the City in terms of a communications issue since Time-of-Use rates are anticipated to be voluntary.

However, the resident comments reinforce one statement previously quoted from the “AMI Health Impact Assessment,” where it was explained that, “Even for seniors who are not low-income, sensitivity to the perceived price [emphasis added] of electrical service can influence a decision not to use air-conditioning during summer heat.”

So it possible that whether or not people participate in the City energy control programs, vulnerable populations may cut back on energy consumption when they need it most, thereby putting their health at risk due to increased exposure to heat or cold.

To read more information from the document entitled, “Affordable Home Energy and Health: Making the Connections,” published by the AARP Public Policy Institute, refer to the link provided below.

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